On August 25, 2022, the Securities and Exchange Commission (SEC) adopted, by a 3-2 vote, the long-anticipated Pay Versus Performance disclosure rules. After two rounds of public comment (see our prior alert and the reopening of the comment period), the adoption of these rules implements Section 953(a) of the Dodd-Frank Act, one of the remaining governance and executive compensation-related provisions applicable to public companies under the Dodd-Frank Act.
SEC Adopts Long-Anticipated Pay Versus Performance Disclosure Rules
Authors
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Lillian Brown
Partner
Co-Chair, Corporate Governance and Disclosure Group
[email protected] +1 202 663 6743+1 202 663 6743
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Jonathan Wolfman
Partner
Co-Chair, Corporate Governance and Disclosure Group
[email protected] +1 617 526 6833+1 617 526 6833